Dear EvalTF,
While these few comments come to you after the deadline, we hope that it
may still be possible to consider them in your work.
Step 2b. "Common Functionality"
The term "Core Functionality" seems a much better choice here. It better
fits the description: "all functionality of a website that, if removed,
fundamentally changes the use or purpose of the website for users"
*Step 4.a: Check for the Broadest Variety of Use Cases*
The second paragraph, starting with the text "To carry out an evaluation
effectively, it is often useful to construct and apply personas..."
over-emphasizes a specific approach, particularly with language like the
second sentence "It is critical to consider...". It should be possible
to evaluate against WCAG 2.0 on a purely technical, objective basis. As
such, this material could be presented as an advisory statement. As
written now it goes beyond the scope of WCAG 2.0 conformance.
Step 4.c: Use Techniques and Failures Where Possible (Optional)
This section appropriately describes the proper use of techniques (that
they are informative and not mandatory). However, the document would be
improved if this were particularly emphasized. We are seeing entities
that are requiring the use of WCAG 2.0 also requiring the use of these
techniques as THE way of demonstrating compliance.
Step 4: Audit the Selected Sample
There was little direction related to web applications related to any
documentation that may have been provided with the web application, or
published by the company selling the web app. For example, the Oracle
whitepaper Testing Oracle Products for Accessibility
<http://www.oracle.com/us/corporate/accessibility/testing-oracle-products-wp-159857.pdf>,
mentions many things related to the accessibility of web applications,
including:
* making sure to read documentation to understand how the product is
meant to be used, such as keystrokes
* documentation that might point out workarounds, including
alternative paths through a website
* enablement of applicable accessibility modes, if any
* if using AT, ensuring that a defect found is not in the AT itself,
and that the user is proficient
* if using automated test tools, ensuring that it is accurately
representing the SC and sufficient/failure techniques that it claims
to meet
**Step 5.b: Provide a Conformance Evaluation Statement**
While the title uses the phrase "statement", within the body it returns
to using the word and concept of "conformance", which, as defined by
WCAG, only exists with perfection.
Also in this section, the note: "*Note:*It is not possible to make an
accessibility evaluation statement for a website that is still in
development" appears to ignore the reality that many websites and web
applications are in "continuous development", and are never finished
(cf. the long lived "beta" applications from a number of well-known
companies).
***5.c: Provide a Performance Score (Optional)*
This is an invitation to consumers of WCAG-EM reports to set a "yes/no"
bar that is at some specific point below 100% perfection (e.g. a score
of 95 or higher is required). Such a move would be of little additional
improvement to the present situation. We do not believe this should be
even a suggested part of WCAG-EM.
Finally, the document in general would benefit from a note mentioning
some of the potential legal ramifications of using WCAG-EM. For
example, if a company creates such a WCAG-EM audit even with the intent
of correcting the items found, it could be used against them in a court
of law (such documents can be found in discovery and would likely be
looked for, even if not published). At a minimum, the document should
advise anyone performing this type of work that it would be wise to
consult legal counsel before starting (this is touched on in the Note at
the end of 5.a, but really should be called out at the top in more detail).
On behalf of my colleagues at Oracle,
Peter
--
Oracle <http://www.oracle.com>
Peter Korn | Accessibility Principal
Phone: +1 650 5069522 <tel:+1%20650%205069522>
500 Oracle Parkway | Redwood City, CA 94065
Green Oracle <http://www.oracle.com/commitment> Oracle is committed to
developing practices and products that help protect the environment